Professor Claims Sex Discrimination in Tenure Denial
by
Joseph C. Maya on Apr. 21, 2017
Employment Employment Employment Discrimination Other Education
Summary: Article about a professor who claims sex discrimination is the reason she was denied tenure.
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In the case of Craine v. Trinity College, a jury rendered a verdict in favor of a professor in her suit against a college on claims of sex discrimination in violation of state and federal law, breach of contract, and negligent misrepresentation. The Superior Court reduced the amount of the verdict. The college appealed, and the appeal was transferred from the appellate court to the Connecticut supreme court.
The action arose after the professor was denied tenure. There are four elements to a case of discrimination where the aggrieved party is alleging illegal denial of tenure: (1) that she belongs to a protected class; (2) that she was qualified for tenure; (3) that, despite her qualifications, she was denied tenure; and (4) that the denial took place under circumstances permitting an inference of discrimination. The college argued on appeal that (1) its motion for judgment notwithstanding the verdict should have been granted, as there was insufficient evidence that it discriminated based on sex, breached the parties' contract, or negligently misrepresented the tenure criteria and (2) it was entitled to a new trial because of, inter alia, inadequate jury instructions. The state supreme court held that a judgment notwithstanding the verdict should have been granted on the sex discrimination claim under Title VII of the Civil Rights Act of 1964, because the professor failed to prove that the legitimate, nondiscriminatory reasons given by the college for denying her tenure were a mere pretext for unlawful discrimination. Evidence that the college deviated from its tenure standards and gave misleading assurances in a 2nd letter of reappointment supported the verdict on the other two claims. The trial court did not abuse its discretion in not instructing the jury that it could not substitute its academic judgment for the college's judgment on the contract claim.
The state supreme court (1) reversed the trial court's denial of a judgment notwithstanding the verdict on the sex discrimination claims, (2) remanded the case to the trial court with directions to grant the college's motion for a judgment notwithstanding the verdict on the sex discrimination claims and to modify the judgment and award accordingly, and (3) affirmed the judgment in all other respects.
If you feel you have been mistreated by your employer or in your place of employment and would like to explore your employment law options, contact the experienced employment law attorneys today at 203-221-3100, or by email at JMaya@mayalaw.com. We have the experience and knowledge you need at this critical juncture. We serve clients in both New York and Connecticut including New Canaan, Bridgeport, White Plains, and Darien.
Source: Craine v. Trinity College, 259 Conn. 625, 791 A.2d 518, 2002 Conn. LEXIS 97 (Conn. 2002)
